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1 <br /> 2 RECITALS <br /> 3 A. On April 6, 2001 (the "Petition Date"), PG&E filed a voluntary petition for <br /> 4 relief under Chapter 11 of the Bankruptcy Code in the above-captioned Court. The Debtor is <br /> 5 a debtor in possession and is operating its business pursuant to 11 U.S.C. §§ 1107 and 1108. <br /> 6 B. Claimant has filed an unsecured, non-priority Proof of Claim in PG&E's <br /> 7 bankruptcy case in the total amount of$1,672.63, assigned claim number 4814 ("the Claim") <br /> 8 based on services provided pre-petition. <br /> 9 C. PG&E asserts certain objections to the Claim. <br /> 10 D. By this Stipulation, Claimant and PG&E seek to fully resolve Claimant's <br /> 11 Claim against PG&E without further litigation, under the terms set forth below. <br /> 12 PG&E and Claimant now agree as follows: <br /> HCViGD 13 STIPULATION <br /> R <br /> �a 14 1. Claimant's Claim, claim number 4814 shall be allowed as an unsecured, non- <br /> , 15 priority claim in the amount of$1,701.66 and shall be treated like other allowed general <br /> 16 unsecured claims in PG&E's bankruptcy case. Unless otherwise provided herein, all other <br /> 17 claims of Claimant shall be disallowed in their entirety. <br /> 18 2. Except as otherwise expressly provided herein, Claimant represents that other <br /> 19 than the Claim, it has neither filed nor asserted any other claim against PG&E or its <br /> 20 bankruptcy estate. <br /> 21 3. Each person executing this Stipulation represents that it has full authority and <br /> 22 capacity to make the commitments contained in this Stipulation. Claimant represents and <br /> 23 warrants that it has neither assigned nor transferred all or any portion of the Claim. <br /> 24 4. Each party shall bear its own costs and attorneys' fees in this matter. <br /> 25 5. This Stipulation shall be effective upon PG&E obtaining any required <br /> 26 Bankruptcy Court approval for entering into and performing its obligations under the <br /> 27 Stipulation, and if no such approval is necessary, upon filing with the Bankruptcy Court. <br /> 28 <br /> WD 101501/1-14199131937609/v4 -2- <br />